Subject to certain ‘thresholds’ (see below), multinational groups may face additional transfer pricing documentation obligations effective as from financial years starting on or after 1 January 2016. The new Dutch transfer pricing documentation requirements involve the preparation of a so-called ‘country-by-country report’, a ‘master file’ and a ‘local country file’. These new documentation requirements aim to implement the results of Action Plan 13 of the OECD’s project on Base Erosion and Profit Shifting.
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